The APESB is proposing to amend APES 110 Code of Ethics for Professional Accountants (including Independence Standards) (the Code) to incorporate changes made by the International Ethics Standards Board for Accountants (IESBA) to the definitions of Listed Entity and Public Interest Entity in the International Code of Ethics for Professional Accountants (including International Independence Standards) (the IESBA Code).

In our submission we support the APESB’s proposals to incorporate the revised definitions into APES 110. We had some comments in relation to the clarity of drafting and need for continued inclusion of certain legacy paragraphs in APES 110 which we encourage the APESB to consider.